"In situations in which there is sufficient concern that a provider is making a recommendation, it may be appropriate to consider whether it can satisfy the conditions of an applicable exception.... For those providers that are dealing with the investment of the assets of non-ERISA IRAs, and who take the position that they are not providing covered recommendations, it should be understood, in analyzing the applicable risks, that the IRA (and its owner) will have no claim against the provider under the Fiduciary Rule[.]"  MORE >>